When the Heller case went before the US Supreme Court in 2008, it got there on an appeal by the District of Columbia which had lost the challenge to its gun ban in the case that started out as the Parker lawsuit. There was much confusion about the impact on gun laws of the Parker/Heller case at the time, among gunowners in particular, as well as the media and the general public. I pointed out at the time, that while it was an important Second Amendment case, the central issue was keeping arms, not keeping and bearing.
DC lost and the Heller decision was proclaimed “historic,” but it did not solve everyone’s concerns about the scope of their Second Amendment rights.
Further decisions were needed. The first of these involved incorporation